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Comentis Launches Vulnerability Support Framework Before FCA Consumer Duty Launch

Clinical regtech provider Comentis has launched its ‘Vulnerability Support Framework’; a new tool available to all professionals regulated by the Financial Conduct Authority (FCA) – guiding them through the complex process of supporting vulnerable customers.

The FCA has estimated that over 50 per cent of the adult population is experiencing circumstances that could result in vulnerability. Despite this worrying statistic, many firms are unable to provide appropriate support after identifying potential vulnerabilities. Consumer Duty is set to come into play on 31 July 2023 and threatens sanctions for those firms failing to provide support for vulnerable customers. With this in mind, the UK regulator and Comentis have developed the new tool.

The Vulnerability Support Framework is a comprehensive document containing immediate and long-term actions for a variety of potential risk factors. Ranging from divorce and bereavement to dementia and low resilience, the vulnerabilities addressed were identified through Comentis’ online customer assessment tool as some of the most widespread.

Comentis developed the framework to better equip firms to provide vulnerable customers with the best possible outcomes but also to encourage the raising of standards across the industry in respect of supporting clients in vulnerable circumstances.

Ensuring ‘good outcomes for at-risk customers’
John Somerville on Comentis FCA Consumer Duty
John Somerville,, head of financial services and professional education at The London Institute of Banking & Finance

John Somerville, head of financial services and professional education at The London Institute of Banking & Finance, commented on the launch. Somerville explained: “As the work to identify vulnerable customers advances, so too do the complexities involved in knowing how to advise them appropriately.

“I have worked with Comentis on various awareness-raising initiatives and their clinical expertise has helped me understand this issue in a much deeper way. This support framework will not only help advisers to develop their own understanding of the complexities of vulnerability but will also offer practical working solutions for challenging situations.”

Tim Farmer, co-founder and clinical director at Comentis, as well as the author of the Vulnerability Support Framework, explained the need for the framework. Farmer said: “Consumer Duty will place identifying and supporting vulnerable customers firmly at the centre of the FCA’s regulation. However, many firms are struggling with the support element of that process. We have therefore created this framework, bringing together best practices from a range of vulnerability specialists, to help determine those crucial next steps.

“What makes this framework so unique is that it’s very much intended as a practical tool, designed not only to educate and encourage the raising of standards but also to provide clinically-informed, in-the-moment instruction for any professional who has identified a financial vulnerability or vulnerable circumstance. It’s also something we plan to build on, with further initiatives to ensure good outcomes for at-risk customers.”

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